Scott v. Kendricks
2025 Ohio 1842
| Ohio Ct. App. | 2025Background
- Antwan Scott filed for parental rights and custody against Sandra Kendricks in 2015; subsequent modifications to child support orders occurred over the years.
- In January 2023, the Franklin County Child Support Enforcement Agency (FCCSEA) recommended an administrative adjustment of the child support amount.
- Scott objected to the adjustment and requested a court hearing; the trial court set and continued several hearing dates, ultimately requiring in-person attendance.
- Scott, residing in California since 2018, requested to appear via video for the hearings but was repeatedly denied.
- On November 1, 2023, the final hearing proceeded in person; Kendricks attended, but Scott did not appear. His objection was dismissed, and the FCCSEA's adjustment was approved.
Issues
| Issue | Scott's Argument | Kendricks' Argument | Held |
|---|---|---|---|
| Was it error to require in-person appearance at the child support hearing? | Scott argued the court should have allowed him to attend by video due to living out of state and difficulty attending in person. | N/A (No responsive argument noted from Kendricks.) | The court held there was no abuse of discretion in requiring in-person attendance; current court policy requires in-person appearances unless ordered otherwise. |
| Did the trial court improperly bar Scott from submitting financial documentation? | Scott claimed he was not allowed to submit necessary documents for the hearing. | N/A | The court found Scott was ordered to bring financial records to the hearing, satisfying statutory process. |
Key Cases Cited
- Booth v. Booth, 44 Ohio St.3d 142 (Ohio 1989) (sets standard of review for child support orders as abuse of discretion)
- Chawla v. Chawla, 2014-Ohio-1188 (10th Dist.) (applies abuse of discretion standard in domestic relations context)